E-mail or other electronic messages sent to SHK Group over the Internet cannot be completely secure as the Internet is an open system. SHK Group does not make any warranty or guarantee with respect to the security of any message sent through Internet or other electronic communication system. The SHK Group will not be responsible for any damage or loss suffered or incurred by any users if they send an e-mail or other electronic message to the SHK Group, or if the SHK Group sends an email or other electronic message at the request of the user, by Internet or other electronic communication system.

PURPOSE OF COLLECTION/USES

SHK Group will not collect any Personal Data that individually identifies a visitor to any SHK Group site unless it has been submitted by users themselves.

SHK Group will endeavour to keep Personal Data held by SHK Group confidential. Nevertheless, in submitting Personal Data you agree that any such data may be used for the following purposes -

4.1.

the processing of applications for, and daily operation of services provided by SHK Group to client and, where appropriate, non-client or to other persons for whom Client acts as guarantor or for whom client provides third-party security;

4.2.

customer relationship management (including but not limited to loyalty programs or privileges and rewards schemes) and relationship management of non-clients such as attendees or participants of seminars or other activities;

4.3.

maintaining client's or any surety's credit history for present and future reference;

4.4.

improving, enhancing, designing or launching existing or new financial services or related products for client's use (including, where appropriate, providing client with financial advice);

4.5.

if the relevant data subject has consented (including an indication of no objection) to the use of the data subject's personal data for direct marketing purposes by members of the SHK Group and/or entities outside the SHK Group in the Account Application or in other application form(s) or otherwise, marketing financial and related services, products or goods.

4.6.

determining the amount of indebtedness owed to or by client or any surety;

4.7.

collecting of amounts outstanding from client or any surety;

4.8.

meeting any requests or requirements to make disclosure under applicable laws and regulations;

4.9.

enabling an actual or proposed assignee of SHK Group in connection with merger, amalgamation, reconstruction or otherwise to evaluate the transaction intended to be the subject of the assignment;

4.10.

any other purpose disclosed in the website(s) or an application form of a member of the SHK Group from time to time;

4.11.

commencing, defending or otherwise participating in any legal or administrative proceedings or inquiry before any court or competent authority;

4.12.

seeking or obtaining administrative, telecommunications, computer, payment, debt collection or securities clearing, custodian, audit, banking, financing, insurance, business consulting, outsourcing, or other services to SHK Group in connection with the operation of its business; and

4.13.

any other lawful purpose directly or indirectly relating or incidental to any of the above.

CLASSES OF POTENTIAL TRANSFEREES

SHK Group will endeavour to keep Personal Data of client or, where appropriate, non-client, held by SHK Group confidential but SHK Group may, at its sole discretion, provide such information to the following persons for direct marketing purposes (where consented (including an indication of no objection) by the relevant data subject) or any other purposes permitted by this Privacy Policy:

5.1.

any agent, contractor or third party service provider (whether in Hong Kong or elsewhere) who provides administrative, telecommunications, computer, payment, debt collection or securities clearing, custodian, audit, banking, financing, insurance, risk management, business consulting, outsourcing, customer relationship management, marketing or other services to SHK Group in connection with the operation of its business;

5.2.

any branch or office of any member of the SHK Group, whether in Hong Kong or elsewhere;

5.3.

any person acting or proposing to act as surety;

5.4.

any person under a duty of confidentiality to SHK Group (or any member of the Group) or who has undertaken to keep such information confidential;

5.5.

any financial institution with which a client has or proposes to have dealings;

5.6.

credit reference agencies and, in the event of default, to debt collection agencies;

5.7.

any actual or proposed assignee or transferee of any member of SHK Group;

5.8.

any person in accordance with applicable laws and regulatory requirements including through or pursuant to any rules, judgment, decision or ruling of the courts, arbitral tribunals, Financial Dispute Resolution Centre Limited, governmental, regulatory or other bodies or institutions, whether as required by the laws and regulatory requirements that are applicable to any member of the Group, or otherwise, or any company issuing a notice under section 329 of the Securities and Futures Ordinance.

ACCESS AND CORRECTION OF PERSONAL DATA

You have the right to request access to and correction of information about you held by SHK Group. If you wish to access or correct your personal data held by SHK Group, please send your written request to the Data Privacy Officer, SHK Group, 28/F, Lee Garden One, 33 Hysan Avenue, Causeway Bay, Hong Kong. SHK Group may charge a reasonable fee for processing any data access request.

OTHER APPLICABLE PERSONAL DATA COLLECTION STATEMENTS

If you are a client of any member of SHK Group, the Personal Data Schedule of the relevant Client Agreement and Schedules shall apply in respect of the relevant account in place of this Privacy Policy, which is general in nature. If Personal Data is collected in a certain activity application form, such as seminar attendance, the personal data collection statement in such application form will supplement this Privacy Policy and in case of any inconsistency, the personal information collection statement in such activity application form shall prevail to the extent of such inconsistency.

OTHER DISCLAIMERS

SHK GROUP ENDEAVOURS TO ENSURE THE ACCURACY AND RELIABILITY OF THE INFORMATION PROVIDED ON OR THROUGH THE WEBSITE(S) OF ANY MEMBER OF SHK GROUP BUT DO NOT WARRANT OR GUARANTEE ITS ACCURACY OR RELIABILITY AND ACCEPTS NO LIABILITY (WHETHER IN TORT OR CONTRACT OR OTHERWISE) FOR ANY LOSS OR DAMAGE ARISING FROM ANY INACCURACIES OR OMISSIONS OR OTHERWISE HOWSOEVER ARISING.

IMPORTANT

By accessing this site and any of its pages you are agreeing the terms and conditions set out above. If you do not agree with this Privacy Policy, you must not access or otherwise use this site or any of its contents. If there is any inconsistency between the English and Chinese versions of this Privacy Policy, the English version shall prevail.

B. OPT-OUT REQUEST FOR THE USE OF PERSONAL DATA FOR DIRECT MARKETING

Request to stop receiving direct marketing materials

According to the Personal Data (Privacy) Ordinance (the "Ordinance"), after providing your personal data, you may at any time opt out from receiving our direct marketing materials. To do so, you may click on the "Unsubscribe" link in any marketing or promotional email that you receive from the SHK Group; or in the form of a written request, you may download a form by clicking here, complete and mail back to the person below. We will process your request free of charge.